ML20234E481

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-309/87-08.Requests Underlying Causes of Violations Articulated in Paragraphs 2 & 3 of 870714 Notice of Violation,Within 30 Days

ML20234E481
Person / Time
Site:	Maine Yankee
Issue date:	09/15/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Randazza J Maine Yankee
References
EA-87-103, NUDOCS 8709220408
Download: ML20234E481 (2)

See also: IR 05000309/1987008

Text

_

_

I

)C3

.

SEP I 5 ;ggy

/

Docket No. 50-309

EA-87-103

Maine-Yankee Atomic Power Company

ATTN: Mr. J. B. Randazza.

Vice President

Nuclear Operations

'

83 Edison Drive

Augusta, Maine 04336

Gentlemen:

Subject:

Inspection Report 50-309/87-08

We have received and reviewed your August 13, 1987 letter (MN-87-91)in

response to our July 14, 1987 letter and Notice of Violation.

Thank you for informing us of the corrective and preventive actions documented

in your letter. .These actions will be reviewed during a future inspection of

your program.

Our review of your response indicates that it describes specific corrective

actions for each of the violations. However, your response did not address

the apparent underlying causes for the violations articulated in paragraphs 2

and 3 of our July 14, 1987 letter.

In retrospect, we recognize that we did

not specifically request your response to these latter issues.

In light of our continued belief that these issues must be resolved to prevent

i

I

degradation of your radiation safety program, you are requested to provide,

within 30 days of the date of this letter, a description of your actions taken

or planned to address the underlying causes of the violations identified.

In particular, your response should address the following concerns as

identified in our letter:

improvement of radiological oversight of station

work activities; improvements in planning for and staffing for outages;

improvements in general housekeeping and radiological control practices; and

improvement in your program for identifying problems, including concerns

i

raised by your staff, and taking appropriate corrective actions.

'

The responses requested by this letter are not subject to the clearance

procedures of the Office of Management and Budget as required by the Paperwork

Reduction Act of 1980, Pub. L. No.96-511.

Sincerely,

Original Signed Bf f

ThomasT.laartin

kD

Thomas T. Martin, Director

DI

O

09

Division of Radiation Safety

G

PDR

and Safeguards

0FFICIAL RECORD COPY

IE k

- _

--

_

_

, _ _ ,

-

q

SEP ! 5' 1987

]

- Maine ~ Yankee Atomic Power Company'

2

,

l

9

.

'

CC:

J

C. E. Monty, President.

1.1

C. D. Frizzle Assistant Vice President / Manager of Operations

"j

.J. H. Garrity, Plant Manager.

1

P. L. Anderson, Project Manager

]

G. D. Whittier, Licensing Section Head-

J.-A. Ritsher, Attorney (Ropes and Gray)

,

i

- Phillip Ahrens Esquire

Public Document Room-(PDR)

l

Local Public Document Room (LPDR).

1

NuclearSafetyInformationCenter(NSIC)

l

NRC Resident Inspector

i

State of Maine

!

bec:

RegionIDocketRoom(withconcurrences)

,

i

ManagementAssistant,DRMA(w/oencl)

DRP Section Chief

i

H..Eichenholz, SRI, Yankee

l

P. Sears, LPM, NRR

,

Robert J. Bores, DRSS

1

l

RI:DRSS-

RI:DRSS

RI:ES

I:DRSS

RI RSS

Nimitz/ejr

Sh

y

Holody

Be

M

t'i n

q

3

9/ti/87

9/// /87

o////87

9/// /87

9//M 87

/

W

k<r

d

e 0FFICIAL RECORD COPY

NOV MY 87-08

UMplol

9/10/87

d

p

- _ _ _ _ - _ _ _ _ _ _ _

g' -__

. - .

• %

v

. 4g

i(

'f

j

X.

MAH)2

UARHEE' Alom/CPOWER00MPARUe

,uougr,Q,Te ,Ta';'s

(20') 623 3521

g

.

,

August'13, 1987

I,

.i

HN-67-91

GDH-87-192

l

'

'/.i

j

(

}ly'<'

)

M

United States huelear Regulatory Comission

'Attent%n:

Documant Control Der,k

'Huhington, D. C,

20555

,

.

.

!

Referstces:

(a)

License No. DPR-36 (Docket No. 50-309)

-

!

(b) USNRC Letter to WAPCo dated July 14, 1987

,

Notice of Violation (NRC Inspection Report 87-08)

(c) USNRC Letter to MYAPCo dated June 2, 1987 - Inspection

,

Report No. 87-08

[

Subject * Reply to a Notice c,f Vioiation

k

Gentl'ement

~

-

1

This letter replies to the Notice of Vio10 tion transmitted via Reference

(b).

These violations were based on inspections of our radiological controls

program and' documented in Reference (c).

l

Our responses follow each of the cited violations, which have been

'

]

restated fer completeness.

The inspectors identified other areas of concern regarding our

radio!ogical controls program and boasekeeping at the close of the 1987

!

refueting. He are pursuing correc'tive actions to address these concerns and

!

would he pleaseo to otscuss this with you at your convenience.

,

,

.,

Very truly yours,

MAIME YANKEE AT0 HIC POWER COMPANY

i

1,

'

l

aw1k

'

G. D. Whittier, Manager

'

Nuclear Engineering and Licensing

j .,

l

GDH/bjp

i

Enclosure

'

cc: Mr. Victor Herses

Mr. M 11 tam T. Russell

Q .-r n o 1 mM 03

<

' " ~

1

Mr. plt Sears

v * ~ '

L

fr. Corne1Ns F. Holden

-I) y'

'

l

,'

?032L-SDC

j

i-

eLA

a

'

e

- . - . _ - - - - -

l

ATTACHMENT A

HAINE. YANKEE RESPONSE TO NOTICE OF VIOLATION

.

l

VIOLATION A

i

Technical Specification 5.11 requires that procedures for personnel

i

radiation protection be prepared and adhered to for all operations

i

'

involving personnel radiation exposure.

Radiation Protection Procedure

9.1.10, Radiation Work Permits, requires, in part, in Section 7.4, that

,

the method of high radiation area control utilized and the surveillance

frequency of ch:cking work in such high radiation area be indicated on the

i

radiation work permit.

Contrary to the above, Radiatior. clork Permit Nos. 87-4-231, 87-4-232, and

87-4-281, used for entries into high radiation areas on April 30, 1987,

did not indicate the method of high radiation area control or the

surveillance frequency of checking the work performed in those areas.

MINE YANKEE RESPONSE TO VIOLATION A

a.

Reason for the Violation *

'

This violation resulted from insufficient procedural guidance on the

development of RHPs.

In trying to write general radiation work

j

permits (RHPs) to allow access to the Containment Building for

'

inspection activities, sometimes involving more than one job,

non-specific High Radiation Area controls (such as " consistent with

.'

job being inspected") were specified.

Since the RHP procedure did

not explicitly prohibit writing such RHPs, the Radiological Controls

personnel assumed it was an acceptable practice.

b.

Corrective Steos Taken and Results Achieved:

All RHPs written for such inspection activities were reviewed and

l

immediately corrected, by specifying on the RHP ' survey meter

required' or ' technician job coverage', when tnis issue was

identified by the inspector.

Radiological Controls personnel were

instructed not to write RHPs with non-specific High Radiation Area

(HRA) controls.

,

!

c.

Corrective Steos that will be Taken to Avoid Further Violations:

1.

The RHP procedure will be revised to explicitly require the

,

identification of specific methods of High Radiation Area

controls on the RHPs. The circumstances surrounding this

violation and the associated corrective actions will be reviewed

'

by all Radiological Controls personnel.

These actions will be

completed by September 1, 1987.

t

d.

Date when Full Comoliance will be Achieved:

Full compliance was achieved on April 30, 1987.

9032L-SDE

- _ _ _ _ _ _ _ _ _ _ _ - _

wome vasace avowc powca courc~y

-2-

\\

.

l

l

VIOLATION B-

,

Technical . Specification 5.12.1 requires, in part, that each high radiation

l

area in which the intensity of radiation is at such levels that a major

,

'

portion of the body could receive in any one hour a dose in excess of 100

mrem be barricaded and conspicuously posted as a high radiation area.

l

Contrary to the above, at approximately 12:00 p.m. on April 27, 1987, a

,

!

high radiation area existed on the -2' elevation of the containment near

l

the Reactor Head Stand, and the barricade and postings for this high

radiation area were inside the 100 mR/hr boundary and thus were not

'

serving as a warr,ing to any one approaching the area. As a result, an

individual in the area could have received a dose to the major portion of

!

the body of 120 mrem in an hour.

_

MAINE YANKEE RESPONSE TO VIOLATION B

!

a.

Reason for the Violation:

This violation appears to have been caused by the relocation of hoses

which, when moved, pushed the barricade toward the radiation source.

Surveys taken prior to the inspector's measurements showed that the

4

High Radiation Area was properly barricaded (and posted), complyi.ng

with the requirements of 10CFR20 and Technical Specification 5.12.1.

-

b.

Corrective Steos Taken and Results Achieved:

The barricade was immediately adjusted to establish a boundary of

!

less than 100 mrem / hour. Other High Radiation Area barricades were

also promptly surveyed and all were in compliance with the

requirements of Technical Specification 5.12.1.

Corrective Steos that will be Taken to Avoid Further Violations:

c.

2.

New barricades, which have spring-mounted uprights that spring

back to the original position if contacted by workers or

equipment, are being fabricated and placed into service.

The

barricade stanchions have heavy base plates.

The location of

the base plate will be marked to denote any movement. Procedure

9.1.6 " Establishing and Posting Controlled Areas" will be

revised to require that survey maps of HRAs indicate barricades

and the dose rates at the barricades.

These actions will be

,

fully implemented by September 1,1987.

d.

Date when Full Comoliance will be Achieved:

Full compliance wa;, achieved on April 27, 1987.

9032L-SOE

_ _ - _ _ _ _ _ _ _ _ _ _

.

_ _ _ ~ . _ _ -

-3-

'

-

4

.

VIOLATION C

~

10 CFR 20.203(c)(iii) requires that each entrance or access point to a

high radiation area be maintained locked with positive access control over

i

each individual entry.

Contrary to the above, on May 10, 1987, access to the Haste Storage Area

adjacent to the Radiation Control Area (RCA) Storage Building was not

maintained under positive access control.

Specifically, scaffolding and a

ladder were located adjacent to a wall of this area which would allow an

individual to reach the top of the wall and gain access to the inside

where radiation dose rates were as high as 2000 mrem /hr.

-

PAINE YANKEE RFSEONSE TO VIOLATION C

c.

Reason for the Violation:

A scaffolding, which had been used during the inspection of the

reactor coolant pump rotating assembly, was inadvertently placed near

the 15 foot high radwaste storage area wall.

Since a ladder at

another location is the normal method of access to the area, the

scaffolding was not recognized as a means of access when it was

,

,

placed against the wall.

b.

Corrective'Steos Taken and Results Achieved:

The scaffolding was immediately moved away from the wall to prevent

unauthorized access to the high radiation area as soon as this matter

was brought to our attention by the inspector.

c.

Corrective Steos that will be Taken to Avoid Further Violations:

l

The wall has been posted to prohibit objects, which could be used for

access, being placed against the wall. Heekly supervisory inspection

tours of the area have shown no further instances of unauthorized

mears of access being placed against the wall.

d.

Date when Full Comoliance will be Achieved:

Full compliance was achieved by July 31, 1987.

)

i

i

9032L-SOE

- _ - _ - - _ _ _ _ _

_

_

_

_ _ ~ _ _ ~ . _ _ _

-4-

I

.

'

VIOLATION D

.

10 CFR 19.12 requires, in part, that all individuals working in or

j

frequenting any portion of a restricted area be kept informed of the

j

storage of radioactive material and precautions to minimize exposure.

Contrary to the above, at approximately 11:00 p.m. on May 8, 1987, certain

workers were standing in a restricted area next to a 55-gallon drum which

I

had contact dose rates of 1200 mrem /hr, and these workers were not

informed that radioactive material was stored in the 55 gallon drum, nor

were they provided precautions to minimize their exposure to the radiation

emanating from the material in this' drum.

MAINE YANKEE RESPONSE TO VIOLATION D

a.

Reason for the Violation:

The workers were not informed of the radiation source because the

technician failed to check the work area as r6 quired by the RHP.

b.

Corrective Steos Taken and Results Achieved:

'

The drum was moved away from the workers and barricaded and' posted as

a High Radiation Area when the inspector brought the matter to our

attention. As soon as the crane was available, the drum was removed

from the refueling cavity.

No other high radiation drums were

introduced into the work area during the reactor head installation.

.

i

c.

Corrective Steos that will be Taken to Avoid Further Violations:

Specific, written instructions for providing RWP job coverage were

provided to all technicians in the Containment Building.

The

instructions included requirements for checking workers' dosimeters,

verifying area dose rates, and keeping radioactive material

containers properly labeled.

Supervisor inspections conducted during

the outage verified that the technicians were complying with these

instructions.

4.

In addition, procedure 9.1.6 will be revised by September 1,

1987 to require proper labeling of all radioactive material

containers.

l

5'.

In order to address a concern raised during the Enforcement

Conference, the removal of reactor head stud hole plugs will be

,

reviewed by the ALARA Committee. This will be completed prior

'

to the next refueling outage.

~

d.

Qate when Full Como11ance will be Achieved:

Full compliance was achieved by May 9, 1987.

9032L-SDE

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _